Last Updated on December 1, 2025 by Melissa Lazaro

Handling BRC V9 Audit Findings With Confidence

Corrective actions are part of every BRC V9 journey. Even strong, well-managed sites receive findings. After supporting multiple facilities through BRC audits, I’ve seen the same uncertainty appear once the closing meeting ends:

“What exactly do we submit? How detailed should it be? And how do we avoid repeat findings next year?”

Responding correctly isn’t just about fixing an issue — it’s about showing the certification body that your system can identify, control, and prevent failures over time. That’s what gives auditors confidence, and that’s ultimately what protects your brand and certification status.

This guide walks you step-by-step through understanding findings, responding effectively, writing strong corrective actions, submitting evidence, and building systems to prevent recurrence.

Understanding BRC V9 Non-Conformity Grades (Minor, Major & Critical)

During the closing meeting, findings are classified into categories — and the severity directly affects timelines, expectations, and sometimes certificate status.

Here’s a quick breakdown:

• Minor Non-Conformity
  A requirement is partly met, or documentation/practice doesn’t fully align — but there’s no direct food-safety or legality risk.
• Major Non-Conformity
  A requirement isn’t met in a way that could impact food safety, legality, or integrity.
• Critical Non-Conformity
  A serious situation where food safety, legality, or product integrity is compromised. This can lead to immediate certification suspension.

The grading isn’t meant to be punitive — it’s a structured way of prioritizing risk.

Pro Tip: Treat every non-conformity seriously. Even minor findings can escalate in later years if they repeat.

A common misconception is thinking a minor issue isn’t urgent. The truth is: repeat minors are one of the fastest ways to damage audit confidence.

Root Cause Analysis (RCA) for BRC V9 Findings — Getting Beyond Symptoms

A corrective action response begins with root cause analysis. Certification bodies want to see that you understand why the issue occurred — not just that you’ve corrected it.

Useful tools include:

• The 5 Why’s
• Fishbone (Ishikawa) Diagram
• Barrier or system analysis

A strong root cause focuses on the system, not the individual. “Operator error” rarely satisfies an auditor unless it’s clear why the oversight happened — lack of clarity, training gaps, poor supervision, unclear expectation, or systemic weakness.

Pro Tip: Your analysis should answer one core question:
“What failed in the system that allowed this finding to occur?”

A small example:
A missed metal detector check isn’t just a missed check — it may indicate gaps in training, unclear accountability, or ineffective oversight.

Writing Strong Corrective Actions (Structure, Clarity & Evidence)

Once the root cause is clear, build your corrective action response. A solid format helps:

1. Restate the finding clearly
2. Describe the immediate fix (correction)
3. Explain the root cause
4. Define longer-term corrective action
5. Explain how effectiveness will be monitored

A strong response is calm, factual, and concise.

Pro Tip: Avoid defensive wording. Auditors aren’t looking for excuses — they’re assessing system maturity and accountability.

A common pitfall is only fixing the symptom. Updating a record without updating a procedure or retraining staff rarely solves anything long-term.

Evidence Submission & Documentation (What the Auditor Expects to See)

Certification bodies need proof that corrective actions are completed and effective. This evidence may include:

• Revised procedures
• Updated forms or logs
• Training records with attendance and competency validation
• Photos or records showing the correction
• CAPA tracking logs
• Internal audit verification

How you present evidence matters. Organized submissions signal reliability and system control.

Pro Tip: Use labelled folders or a structured PDF with a clear index — make it easy to review.

Sending everything you can find in panic mode doesn’t help. Clear, targeted evidence always performs better.

Monitoring Effectiveness & Preventing Recurrence (Closing the Loop)

Corrective action doesn’t end when documents are uploaded. The site must show the improvement is lasting.

This can be done through:

• Follow-up checks
• Trending data
• Internal audit verification
• Management review updates
• Performance metrics

Effectiveness reviews are often performed at 30, 60, and 90 days depending on the risk level.

Pro Tip: Treat trend analysis as early warning — not a report card.

One facility identified a slow increase in hand-washing non-compliances. Because they monitored proactively, they updated training before it became an audit finding the following year.

Building a Continuous Improvement System (Not Just Fixing Findings)

Strong corrective actions feed back into the system and strengthen:

• Risk assessments
• HACCP decisions
• PRPs
• SOPs
• Training programs
• Supplier controls
• Culture maturity

Sites that handle findings well typically see fewer repeated issues and smoother audits over time.

Pro Tip: Create a corrective-action lessons-learned log. It helps avoid repeated problems — especially during staff turnover.

FAQs: Corrective Actions & BRC V9 Non-Conformities

Q1: How fast do we need to submit corrective actions?
Certification bodies typically expect submission within a defined timeframe (often 28 days), so planning and ownership are important.

Q2: Can a minor non-conformity become a major next year?
Yes — repeated minors often indicate weak corrective action or ineffective system controls.

Q3: Can templates be used?
Yes — but the content must reflect actual site conditions. Auditors can immediately tell when responses are generic.

Conclusion: Responding to Findings With Professionalism & Structure

Corrective actions aren’t about proving perfection — they’re about proving control. When your responses are structured, root cause is clear, evidence is organized, and actions prevent recurrence, certification bodies gain confidence in your system.

If you’d like help reviewing a response before submission or creating a reusable corrective-action framework, I can build one based on your risk level and audit history.